Conflict of Succession Laws - Definitions

Definitions

In civil law systems, there are two types of property. Out of comity, the conflict of laws has adopted the terminology of civil law:

  • Immovables is the equivalent of "real property" in common law systems, i.e. it is land or any permanent feature or structure above or below the surface.
  • All other property is considered movables, the equivalent of personal property or personalty in common law systems. This property is either tangible or intangible, in that it is either physical property that can be touched like a computer. Alternatively, it is an enforceable right like a patent, other types of intellectual property, or a chose in action such as shares and bank accounts.

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